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NY L89979

February 7, 2006

CLA-2-85:RR:NC:1:110 L89979


TARIFF NO.: 8537.10.9070

Ms. Heather Ganley
Taco, Inc.
1160 Cranston Street
Cranston, RI 02920

RE: The tariff classification of a circulator module from Canada.

Dear Ms. Ganley:

In your letter dated January 17, 2006, you requested a tariff classification ruling.

The merchandise under consideration is the VR Module. The VR Module is a variable speed printed circuit board (PCB) used in the Taco Variable Speed – Outdoor Reset “00” Cartridge Circulator (00-VR). A sample of the module was submitted with your ruling request.

The Taco Variable Speed – Outdoor Reset “00” Cartridge Circulator (00-VR) is a microprocessor-based pump designed to regulate the flow of water to a heating system through variable speed injection mixing. Variable speed injection mixing uses a variable speed pump to inject hot water when needed in low temperature heating zone systems such as radiant heating. The VR Module receives information from a thermostat and from sensors used for monitoring outdoor temperature and the supply and return water temperatures of the boiler. By monitoring the heated areas requirements, outdoor temperature and water temperature, the VR Module regulates the supply of hot water to the heated area. The module does not maintain the temperature in the heated area or the water temperature of the boiler; it controls the speed of the circulator pump. The outdoor sensor is used to make the heating system proactive instead of reactive to changes in outdoor temperature. If the outdoor temperature drops rapidly, the pump speeds up, increasing the circulation of hot water into the heated area. If the outdoor temperature increases, the pump speed will decrease limiting the flow of additional hot water. This sensitivity to outdoor temperature changes limits rapid variations in the temperature of the headed area.

The VR Module measures approximately 3 inches square and is populated with various integrated circuits (IC), capacitors, light emitting diodes (LEDs), connectors and DIP (Dual In-Line Package) switches used for optional temperature range settings.

We considered classification under HTS 9032. However, in your request you state that, if the output of an external thermostat is not connected to the VR module, the pump will run continuously, thus, we note, independently of the desired temperature in the heated area. From information in other parts of your submission, the pump will shut off only when the outside temperature is above 70° F (if DIP switch #4 is turned on), but that is an out of the ordinary situation in most parts of the USA during the heating season. The device that has inputs from thermal sensors in the heated area and which determines if heat is or is not ordinarily needed to maintain the temperature of the heated area at the desired level, is the separate thermostat which is not part of the module. This precludes classification of the VR Module under heading 9032 (HTSUS).

The applicable subheading for the VR Module will be 8537.10.9070, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Boards, panels, consolesand other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricityFor a voltage not exceeding 1,000 V: Other: Other: Other.” The general rate of duty will be 2.7 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Thomas Campanelli at 646-733-3016.


Robert B. Swierupski

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